Coming Soon: “Dirty Air” That Only Exists On A Hard Drive

The USEPA has a problem: the air in the United States keeps getting cleaner and cleaner. Obviously the Agency can’t justify its current level of funding if they say the air is clean enough, no matter how clean it is. The game that the Agency has played on a regular basis is to use its authority under the Clean Air Act to effectively redefine what clean air is. Thus, while the vast majority of the nation has long since met the ambient air quality standards set forth in the original Clean Air Act, the EPA has kept itself in business by continually moving the goalposts farther and farther back.

This behavior isn’t limited to the Obama administration. They did the same thing under Clinton and under Bush II. (The difference being that environmental groups applauded reductions in standards under Clinton, but when Dubya lowered a standard even lower, he was condemned for not going far enough). Under Obama, the EPA has reduced the ambient air quality standards for two common air pollutants: nitrogen dioxide and sulfur dioxide. The former is generated by any form of combustion (cars, trucks, fireplaces, power plants, water heaters, etc.). The latter is primarily generated by coal combustion.

With that as background, we’re going to talk about the sulfur dioxide standard and how this EPA is doing much more than moving the goal posts back again. There’s some technical stuff involved here, but fear not – the foundation of my career is explaining technical concepts in an understandable (and sometimes entertaining even) way. It’s important to understand this issue, for it’s going to affect everyone’s lives in the form of the price and availability of power in America. It’s also kind of brilliant, not in the “this will make the world a better place” kind of brilliant, but in a “Bond villain coming up with his master plan” kind of way.

So, as we said the EPA has relied on numeric standards for common air pollutants to determine what parts of the nation have clean air and which have dirty air. They’ve been doing this since the Clean Air Act began. For example, the annual standard for nitrogen dioxide in the air is 53 parts per billion. If you live in a county where the average nitrogen dioxide concentration is 40 parts per billion in a year, the Agency deems the county “in attainment” with the standard and you officially live in a county with clean air (at least for this pollutant). Congratulations. However, if you live in a county where the average nitrogen dioxide concentration is 61 parts per billion, then the Agency deems the county to be “non-attainment” and you officially live in a county with dirty air. (Boo, hiss).

There are consequences to being in non-attainment, in the form of more federal oversight, more control requirements and a whole lot more rules. It’s tougher to build new facilities in a non-attainment area if the new plant will emit the pollutant causing the problem. So this distinction between attainment and non-attainment is a pretty big deal. It’s an even bigger deal if you happen to be a President who believes that the more government controls the way things are done in the private sector, the closer to nirvana we are. A President of that mindset wants all of the non-attainment areas he can get, so the EPA can get in there and REALLY put the “control” in “command and control” regulations.

There’s an extra special bonus for having lots of counties in non-attainment with sulfur dioxide standards if you happen to be a President who regularly drinks the Kool-Aid served up by the most extreme environmental groups. As noted earlier, sulfur dioxide primarily comes from coal combustion and the folks at extreme environmental groups would sell their souls, or their collection of vintage Birkenstocks (which may be the same thing) to shut down coal plants forever. Accordingly, if our wholly theoretical president creates a bunch sulfur dioxide non-attainment areas, he also creates a bunch of new ways to wage the war on coal that his wholly theoretical enviro-activist supporters prize so much.

Toward that end, Obama’s EPA created a new short term sulfur dioxide standard of 75 parts per billion based on a one hour averaging time. For a lot of technical reasons that would bore the snot out of you, that’s a whole lot tighter than the old short term standard. Still, the EPA wanted to make double dog sure that it would have lots of sulfur-dioxide non-attainment areas, so they came up with a fiendishly ingenious means of doing so: rather than relying on actual scientific data to determine compliance with the standard, they would rely on theoretical data instead!

You see, heretofore we’ve determined which areas do or do not meet ambient air quality standards by actually measuring the amount of pollution in the air. Towards this end, the EPA and state agencies operate networks of thousands of ambient air monitors that cheerfully run year round, spewing out mountains of data that is duly checked, evaluated and measured against the applicable ambient air standard by the gnomes that the EPA has bred especially for this purpose.

But Lisa Jackson is determined to change that antiquated system. Evaluating air quality by using actual air quality data is so 2008. Nope, when it comes to this new sulfur dioxide standard, the EPA has directed states to base compliance on computer modeling alone.

One wonders if this approach is inspired by the global warming crowd? Computer modeling is plenty enough to get the nation’s collective knickers in a knot over greenhouse gases, maybe that’ll work for sulfur dioxide too!

So what’s the problem with using models? Well, for one we know that the models are tremendously conservative. That is, they vastly over-estimate ambient air concentrations of pollutants, often by a factor of four or more. We know this because we can compare what the model predicts to real-world measurements. For another, when you do modeling you generate worst case conditions that don’t actually happen in the real world. You pretend that every single source in the model is operating at maximum rates all at the same time and emitting the maximum allowable amount of pollution. You also model at a wide variety of weather conditions – five years’ worth of meteorological data in fact. And finally, you determine the ground level concentrations at thousands of points for each and every hour of those five years. And, if the unreal production rate assumptions converges with just the right weather conditions at a single one of those thousands of points for a single hour, well the – voila! – you’ve got yourself a violation of the standard! Collect a few hours like that and – poof! – you’ve got yourself a non-attainment area!

As I said, it’s kind of a brilliant scheme. Many of us in the business have started checking out how this approach will affect them by doing some preliminary modeling. And, we’ve found that even plants that emit modest amounts of sulfur dioxide throw counties into theoretical non-attainment, which is of course real non-attainment according to Ms. Jackson. There doesn’t appear to be any way around it.

So, as the states start completing their modeling, we’re going to have new sulfur dioxide non-attainment areas all over the place, even though there is far less sulfur dioxide in the air than there was even ten years ago. Neither the EPA nor environmental groups will put the new non-attainment in areas in that context of course, or explain how they came to be. They will rather prepare press releases damning coal and calling for drastic action. And then nitwits like Paul Krugman will churn out columns deploring the state of the air in the United States and how the power industry is out to kill us all. We’ve seen it before and, thanks to this latest bit of idiocy, we’ll see it play out again.

Is anybody in the MSM going to get into the details to explain how twisted this is? Don’t hold your breath. For most of today’s “journalists” in the MSM today, research consists of collecting talking points, not delving into details. Is anybody in Congress going to hold the EPA accountable for playing games like this? Man, I sure hope so. If not, you’re not going to very happy with your electric bills in the near future.

Richard J. Trzupek is a chemist who has been employed as an environmental consultant to industry for more than 25 years. He specializes in air quality issues, has worked for several Fortune 500 companies, has participated in the development of environmental legislation and regulation and is currently principal consultant at Trinity Consultants based in Oakbrook Terrace, Illinois.